Scottish Government

CHAPTER 10: LOCAL AUTHORITIES

Local authorities have a statutory duty to collect and dispose of household waste and a large proportion of waste collected from households goes into landfill sites. Under the Landfill Allowance Scheme, which came into force in 2005, local authorities have a set limit on the amount of biodegradable municipal waste ( BMW) they may send to landfill and consequently are looking at schemes to help meet their targets; this will, in turn, help Scotland to meet its obligations for reducing landfill of BMW under the EC Landfill Directive.

The bulk of comments in this section of the consultation came, not surprisingly, from the twenty local authorities who responded to the consultation. While a broad range of issues were covered by respondents in response to the questions in this section of the consultation paper, most were made only by a single respondent. Where possible, points have been grouped together and reported on. A full list of the points raised is appended to this report.

10.1 SIZE OF BINS AND FREQUENCY OF COLLECTIONS

The 1990 Environmental Protection Act places a duty on local authorities to collect household waste and most local authorities have kerbside waste collections on a weekly basis. In addition to general household or communal bins, some local authorities have introduced recycling bins including those for green waste or for paper.

The London Borough of Barnet has interpreted the Act as giving it powers to make recycling compulsory, while some other authorities have used this power to limit the amount of waste they collect and thereby encourage recycling. The consultation asked, "Do consultees consider that there would be merit in a similar approach to Barnet's (making use of certain receptacles mandatory, to encourage recycling) being adopted by local authorities in Scotland? Clearly, before authorities in Scotland took any action of this type, they would need to be satisfied about the scope of the existing legislative powers in Scotland."

Seventeen of the 52 respondents commenting on question 29 voiced agreement with this proposal and this included 4 local authorities. Five respondents felt that these powers should be more widely known. Ten voiced disagreement and, again, this figure included 4 local authorities. Six respondents felt that more research was needed to gauge success of existing schemes.

The key theme to emerge in relation to mandatory recycling was the comment that some local authorities have already chosen to operate similar schemes; 10 respondents (including 7 local authorities), felt this should be left to the individual authorities to decide.

"Several local authorities in Scotland, (including the respondent council) , have already introduced the mandatory use of containers provided by the authority to encourage recycling. Strict monitoring of the use of these containers is required to ensure maximum recycling."
Local authority

There was a perception that the scheme might be hard to enforce, with 8 respondents (including 3 local authorities) voicing concern over regulation and enforcement. Three local authorities and 2 other respondents saw the need for clarification of existing regulations in this area. Two respondents felt there needed to be a unified approach to dealing with households who chose not to comply. One local authority voiced concern that this approach could lead to friction between authorities and householders.

There was a view that individuals should aim towards recycling being their initial consideration when disposing of waste, and 7 respondents felt that households are, or would be, happy to recycle. "Recycling when feasible should be regarded as a norm for all good citizens, not an option for the environmentally committed." (Academic / Professional). However, 5 respondents commented on the need to ensure that variation in households and householders were catered for, and the elderly and disabled as well as those living in tenement housing were mentioned. Five respondents felt that more education and encouragement to recycle would be needed.

Costs were mentioned; 4 respondents felt these would rise as extra staff and new technology would be needed. Two respondents raised questions over whether this would be self-funded - perhaps through fines - or whether the Scottish Executive would provide funding.

Three respondents worried that the suggested approach would shift the emphasis away from waste prevention and 3 others felt that these measures would be premature and counter productive, suggesting full implementation of the voluntary kerb-side collection scheme first.

Other comments, largely from local authorities included:

• That compulsion may be needed if local authorities are faced with landfill penalties (2 respondents);
• Possible dishonesty - using neighbour's bins (2 respondents);
• Possible increase in fly-tipping (2 respondents);
• That some form of incentive may be needed (2 respondents).

At question 30 the consultation asked, "Should the Scottish Executive consider action in relation to the size of bins for residual waste provided by local authorities and/or the frequency of collection by local authorities? If so, what action should be taken? Potential options include:

• (Option 1): Primary legislation on bin sizes and frequency of collection. However, this would take a number of years to be enacted. It also might mean a high degree of central control on an issue where there are bound to be local variations (e.g. type of housing stock; nature of recycling services provided).
• (Option 2): Advice on size of residual bins and frequency of collections. It might be possible to provide such advice during the work on best practice in recycling which the Executive plans to carry out with authorities over the next year.
• (Option 3): Making funding streams, such as the Strategic Waste Fund and Grant Aided Expenditure for refuse services, relate directly to size of bins and frequency of collections"

As table 10.1 indicates, option 2 received the most support; from 17 out of the 51 respondents replying at question 30. Of the 11 local authorities responding to this question, 9 were in support of option 2.

Table 10.1
Preference for options given at question 30

Twelve local authorities and 4 other respondents commented on the need to provide whatever service is best for the area and 15 respondents stressed that local authorities should be allowed to make these decisions. As one local authority pointed out "A 'one service suits all approach' would not be appropriate or best value in many circumstances." Eight respondents pointed out that some local authorities have already reduced their collections and 7 respondents voiced the opinion that this method is more effective than reducing bin size.

Five respondents, including 3 local authorities, felt that no action should be taken, and some respondents did not state a preference.

The need for some sort of incentive, perhaps a council tax rebate, was suggested by 4 respondents. A further 6 respondents felt that while reduced collections may prove unpopular, there was some evidence that they do encourage recycling.

Concern over provision of services for different types of households and householders was again raised by 8 respondents.

"Making these ideas mandatory ignores the fundamental fact that households vary enormously, both in the waste they produce and in how they handle it. People do not like being treated as averages, nor do they like being treated as a 'special case.' However, huge variation has to be catered for."
Community council

Concern over the cost of implementing changes, especially in relation to altering bin size, was voiced by 6 respondents who felt that the money could be better used elsewhere. Three respondents felt more research was needed into which option would be most effective.

There was a suggestion that standardisation would be useful, and 6 respondents (including 4 local authorities) suggested that bin sizes, collections and colours should be the same throughout the country. Consistent, central guidance and guidelines would also be useful and 5 respondents wanted to see practical, applicable guidelines for local authorities.

At the consultation event there was a discussion on one local authority who had successfully reduced their collections.

Case History - Midlothian Council (Consultation event)

The Council changed to a fortnightly collection for residuals with recyclate picked up weekly. Large families or families with children in nappies get a larger bin - but only in the short term.

The amount collected has decreased by 40% and the recycling rate has gone up. There has been a lot of political support from Councillors to do this. The workforce has increased by 60%.

In general, householders accepted this change, although there had been a few problems with hygiene. There will also have to be an increase in the number of routes offered.

One of the reasons for success was because it has been done in-house, so there was flexibility built in.

However, it is important to ensure that this is not seen as a reduction in service.

10.2 GREEN WASTE COLLECTION

Many local authorities have introduced green waste collections in their areas and this adds to the recycling-composting rates. Kerb-side collections have, however, the effect of increasing the amount of waste collected as householders dispose of garden waste into these bins rather than dealing with it themselves through composting or disposal at a civic amenity site (recycling centre).

Question 31 of the consultation document asked, "Do you think that further research and guidance is required on green waste composting to minimise the effect on waste arisings? As indicated below, local authorities are already empowered to charge for the uplift of garden waste."

Out of the 48 respondents commenting at question 31, 19 voiced their support for further research or guidance, with only 2 disagreeing.

Guidance was requested on how to encourage and educate householders on composting issues and 12 respondents (including 7 local authorities) felt that education was key.

Research into composting is currently underway by WRAP and other agencies, and 10 respondents felt this should be examined.

" WRAP will shortly be publishing the outcome of a significant piece of research which identifies the optimal approach to organic waste in the municipal waste stream. This is likely to propose greater emphasis on home composting and separate food waste collections with a reduced role for free garden waste collections."
Other public body / publicly-funded body

A key issue to consider is that kerbside collection may discourage composting and 6 respondents felt that collections should only continue where composting proves problematic, for example in flatted properties. Three respondents felt that charges for green waste collection should be national policy.

The consultation document acknowledged that more green waste collection may mean more waste entering the stream and 6 respondents agreed with this point, while a further 3 commented that green waste collection is only worthwhile if waste is removed from the waste stream. Three local authorities, however, viewed green waste collection as an integral part of the waste collection service.

Five respondents were concerned that charging for green waste collection may mean an increase of landfilling biodegradable material with waste being disposed of in general bins or by fly-tipping.

The need to suit green waste collection services to each individual areas was raised by 4 respondents and 4 respondents requested guidance for local authorities on this issue.

Two local authorities commented that excluding home composting from landfill diversion targets excludes the use of this waste prevention technique. Three respondents, including 2 local authorities, commented that including home composting schemes in waste diversion figures would lead to local authorities being more inclined to promote home composting.

Three respondents disagreed with the statement in the consultation document that "there is a good market for compost meeting the PAS 100 standard".

10.3 CHARGING

Local authorities make no charge for household waste collection and under the terms of the Environmental Protection Act 1990 they are not allowed to do so. However, they can - and in many cases do - charge for uplifting bulky waste. They may also charge for garden waste collection although this is not common practice.

In order to allow local authorities to impose charges for waste collection, primary legislation would be needed. One option for charging is that of "direct variable charging", also known as "pay as you throw". Under this type of charging scheme, households are charged depending on the amount of waste they place in their general bin. The downside is that this type of charging can have adverse effects on those with lower incomes and may lead to an increase in fly-tipping.

The consultation asked 3 questions in relation to charging:

Question 32 asked, "Should the Scottish Executive consider amending the existing regulations allowing charges to be made for the collection of other types of household waste. If so, what changes should be made, and why?"

Although 11 of the 54 respondents commenting at question 32 agreed with this proposal (in comparison to 7 who disagreed), the main comment, made by 15 respondents, including 5 local authorities, was the concern over a possible increase in fly-tipping or other illegal disposal practices. This issue was raised throughout the section on charging, with 7 respondents asking for guidance on fly-tipping specifically at question 33 and 7 commenting that fly-tipping may be a result of the direct variable charges at question 34.

"Whilst we support the general principle that producers and consumers should be responsible for the environmental costs of their actions, there are potential risks to the natural heritage from charging for uplift of waste. As the consultation notes, charging can lead to an increase in fly-tipping, which impacts adversely on visual amenity and on wildlife and habitats. The impacts from fly-tipping of garden waste include the potential risks to biodiversity of garden plants becoming established."
Other public body / publicly-funded body

As has been seen in responses to other questions, the need for flexibility was seen as an important factor by 9 respondents (including 6 local authorities) who felt authorities should decide what was best for their own areas. This issue was also raised at question 33 with 9 comments on local discretion and at question 34 by 3 respondents. One local authority commented "Due to local variations e.g. socio-demographic factors, we consider local authority control for setting the level of charges for other types of household waste should remain."

Five respondents commented on the need to treat the causes of waste. Seven respondents (including 4 local authorities) felt that the Scottish Executive should not consider amending regulations.

Suggestions on which charges should be imposed included:

• Hazardous waste (5 respondents);
• Bulk waste - to encourage re-use (4 respondents);
• Garden waste (1 respondent);
• Charge for disposal rather than collection (1 respondent).

Five local authorities commented on the need to change consumer behaviour and felt that charges could help towards this goal, although 2 other local authorities acknowledged that charges would prove unpopular.

Guidance on possible exemptions for those on low incomes was requested by 5 respondents and this theme was repeated at question 33 where 3 respondents again asked for guidance.

Further research was seen as important by 4 respondents in order to identify the pros and cons of charges and 3 respondents mentioned the need to research the use of incentives rather than charges.

The need for consistency, across all areas as well as all waste types, was seen as an important issue with 3 respondents mentioning the need for standardised charges.

Question 33 asked, "Should the Scottish Executive consider issuing guidance on charging for special uplifts of bulky items and garden waste? If yes, what should the guidance say?"

Views on this proposal were split, with equal numbers of respondents voicing support and opposition for this specifically. Nine respondents (including 3 local authorities) voiced support for this proposal; 9 respondents (including 4 local authorities) disagreed.

The main point made at question 33, by 10 of the 49 respondents commenting here, was that if guidance were to be issued it should include a fair, consistent, basic charging structure or guidance on calculating this. Five respondents wanted to see robust, best practice guidance. "The Scottish Executive should however consider reviewing all collection (and charging) policies and issue an annual summary citing what they consider to be good practice." (Local authority)

Six respondents felt that the guidance should be issued to householders and could include information on limits, charges and benefits as well as specific local recycling information.

Two local authorities felt that guidance would be needed on the impact of charging and two respondents asked for guidance on the scope of existing powers. "The EPA 1990 does allow for charging although many see the legislation as implicit rather than explicit. Any amended legislation should be robust and explicit." (Local authority)

Other suggested areas in which guidance was felt useful included:

• Contracting out to the community sector (2 respondents);
• The use of incentives (1 respondent);
• A clearer definition of household waste (1 respondent);
• Ability to pay (1 respondent).

Question 34 asked, "Do consultees consider that it would be helpful to consider further the issues about "direct variable charging"? The next step would be to issue a full consultation paper on this subject, outlining the arguments for and against and the financial implications."

Fifty-five respondents commented on question 34 with 21 respondents voicing support for this proposal. A further 6 respondents stated that they would welcome a full consultation on the subject, and 9 commented on the need for further research on a variety of issues such as enforcement, impact, cost and technologies. Seven respondents felt research was needed to ensure that direct variable charging did not impact disproportionately on any particular group or area. A public body / publicly funded body commented " As long as appropriate safeguards are in place to protect socially and geographically disadvantaged populations, ( …. ) would strongly agree with sentiments to introduce 'direct variable charging'. This creates a link between the waste we produce and the cost of handling and disposing of the non recyclable elements."

While 6 respondents felt direct variable charging would not be a helpful step, 6 other respondents (including 3 local authorities) felt that it may be of interest in the long term but should not be seen as a short term measure. Reasons given included the need to ensure the correct infrastructure or to maintain public confidence.

The success of similar charging schemes was discussed. Five respondents felt the experiences of other countries should be examined and 5 others commented on the success of such schemes overseas. One respondent from the packaging sub-group commented "Such charging has proved successful in Scandinavian countries where the effects of a household's waste behaviour are shown directly on the council tax bill. Check it out ! Stop saying 'It'll never work here."

Concerns over the costs of implementation were raised by 4 respondents, with 3 respondents noting that these would not justify any other benefit. Other concerns included the problem of identifying which households to charge, especially in cases where communal bins are used (this issue was raised by 3 respondents).

At the consultation event, attendees raised many of these issues during discussions, although they were generally supportive of further work in this area. Key points raised were:

• Variable charging is fair
• Variable charging makes the connection between consumer and waste produced
• Fixed charge for failing to recycle would be easiest option
• Tenements would pose a problem
• Not everyone has a recycling service, so charge could be unfair
• At what point would you bring in a charge?
• How would you enforce a charge and that costs of enforcement would be high
• Bin weighing is expensive and impacts on time required for collection rounds
• Flytipping potential
• It would prompt consumer demand for low waste products
• There are different ways of charging - by weight, volume, frequency, bag and tag etc
• Surveys show that people think of waste as the no1. service they receive from their local authority
• Charging would probably be met with resistance by the public - would have to be done at a national level and not a voluntary or local level (some disagreement on this)
• The quality of recyclate could be affected
• There could be a disproportionate effect on low income households

Overall, these individuals were supportive of further work in this area.

10.4 INCENTIVES

As an alternative to charging, incentives could be used to encourage recycling and waste prevention measures, and incentive schemes are proposed or underway in some other parts of the UK and further afield. The consultation asked "Do consultees consider the Scottish Executive should carry out further work on incentives? If so, what? One option would be trials of incentives with a number of authorities."

Twenty-two of the 52 respondents commenting on incentives voiced their agreement that further work should be carried out and this included 8 local authorities. Six respondents disagreed, with 5 commenting that it seemed very time-consuming or costly for little gain. However, incentives were seen as a more positive measure than charges and 3 respondents stressed the need for positive reinforcement of waste awareness.

A pilot scheme was proposed by 14 respondents (including 6 local authorities). The need for research or to examine results from other countries was suggested by 7 respondents and the WRAP front-of-store research was specifically mentioned by 3 respondents.

"Yes, the Council supports pilot schemes or trials to assess options for recycling incentives. The success of incentive schemes can only be judged in real life situations, therefore to assess the practicality of incentive schemes trials would have to be undertaken, then if successful rolled out to a wider area and re-evaluated."
Local authority

Any incentive scheme would need to be seen as fair to all households and 6 respondents wanted to see equal access to all facilities or services.

Comments on the need to examine the use of incentives within the wider context of whole waste life-cycle were made by 4 respondents.

Suggested incentives included:

• Council tax rebates (3 respondents);
• Recycling credits (2 respondents);
• Prize draws (1 respondent);
• Funds for charity (1 respondent);
• Tie-in with loyalty card schemes (1 respondent).

It was also suggested, by 3 respondents, that there be incentives for local authorities in meeting or exceeding targets.

Two respondents commented that central funding would be needed, although 1 local authority felt that any incentive scheme should aim to be self-financing and one local authority felt that funding could come from manufacturers.

Similar points both for and against the use of incentives were raised by attendees at the consultation event. Key points were:

• Do not think incentives are a good idea - it is taxpayers money that is being used. People have been recycling for years and should be doing it anyway. Need more of a stick, not a carrot.
• There is not 'one solution' to waste growth - we should be looking at anything that might reduce generation - including incentives
• Incentives could go hand in hand with the stick.
• Incentives are not necessarily long term - they should be used to change behaviour and then gradually withdrawn.
• Can only roll out when 100% of households have the opportunity to recycle
• Difficult with tenements.
• It's how you sell it - say that low waste households get a discount, rather than saying that high waste households are penalised.
• How do you address prevention - as distinct from recycling?
• How do you measure reduction?
• Need an open mind on the whole subject - it may mean a major change in the way we do things
• Local authorities are at the end of the line - manufacturing is where greatest impact can be achieved.

10.5 WASTE CONTRACTS

The consultation highlighted the need for waste management contracts / service level agreements to ensure that they do not encourage the generation of waste. Question 36 asked, "Do consultees consider that waste management contracts/service level agreements should include incentives for waste prevention? If yes, how is this best achieved? Do consultees consider that waste management contracts/service level agreements can currently include perverse incentives to increase the generation of waste? If yes, what can be done to tackle this?"

Forty-seven respondents commented on question 36, and 13 (including 5 local authorities) agreed that SLAs or Waste Management Contracts ( WMC) should include incentives for waste prevention. Ten respondents specified incentives to re-use, recycle or divert waste; this could include the provision of recycling credits. Seven respondents wanted to see contracts including a waste reduction requirement. One respondent from the community sector replied "Yes they should, need to move away from the concept that the more waste you process the better. Not sure how!"

One major concern, voiced by 9 respondents (6 of whom were local authorities) was that current WMCs are linked to tonnage rather than volume, making heavier goods more financially rewarding. Two local authorities felt that contracts should be aimed at reducing capacity of tonnage as the end result.

Disagreement was voiced by 5 respondents, including 1 local authority, and 7 respondents commented that contractors have no control over the amount of waste generated. Landfill shortfall was of concern to 4 respondents and there was a comment from one local authority that "As it is the Scottish Executive that encourages PPP or PFI projects and it is very hesitant to encourage authorities to strike out on their own, then the least the Scottish Executive could do is offer to pay any financial penalties local authorities incur for not landfilling enough waste."

Research into best practice, environmental impact or the need for scenario planning was highlighted by 6 respondents. Two local authorities felt that SLAs needed to provide an auditable trail of waste disposal.

There were 2 comments on the need to research sustainable construction or the problems of building waste.

10.6 OTHER CONTRACTS

The consultation document states the "local authorities have considerable purchasing power" and can therefore influence demand for "green" products. Question 37 asked, "Do you consider that contracts (other than waste management) let by local authorities have scope for provisions on waste prevention? If so, which ones? There is clear scope to minimise waste in construction, although this may not impact on household waste. The best time to make adjustments to contracts may be when they are due to be renewed/relet."

Forty-five respondents commented on question 37 with 11 voicing their agreement that there was scope for provisions on waste prevention in local authority contracts. Only 1 respondent - a community council - felt this was unlikely, and 1 local authority commented that these provisions would have little impact on household waste.

Waste prevention measures were mentioned by 12 respondents (9 of whom were local authorities) and included recycling, re-use, sustainability and disposal. One local authority commented,

"All contracts issued by authorities should be evaluated on a range of factors, these should include sustainability, waste minimisation, recycling content, and ease of disposal at the end of their life. These issues should be written into the council's purchasing/contract standing orders to ensure the Best Practicable Environmental Option is designed into the purchase at the start."

Some respondents commented on specific contract types including contracts for:

• Civil engineering, construction or demolition (9 respondents);
• Office furniture or housing department furniture purchases (7 respondents);
• Catering or school catering (4 respondents);
• IT equipment (3 respondents);
• Office materials or supplies (3 respondents);
• House clearances (3 respondents);
• Landscaping (2 respondents);
• Cleaning services (1 respondent);
• All tradesmen (1 respondent).

In addition, 6 respondents felt these provisions should be included in all public sector procurement contracts, with 4 respondents voicing the need for "green" procurement policies to be standard.

"The McClelland Report with its recommendations on centralising much public sector procurement has a great opportunity to embed good sustainability practices into contracts led and let by the Executive and its associated bodies."
Individual

Guidance, perhaps in the form of an eco-footprint tool, for procurement officers was seen as essential with 4 respondents commenting on the need for guidelines on standard requirements. A kitemark or standards were suggested by 3 respondents.

Three respondents felt these measures should only apply if the real cost benefit proved to be greater than an increase in contract costs.

The need to make use of experience developed by WRAP or Envirowise was mentioned by 1 local authority while another asked for guidance on compliance with EU procurement rules.

10.7 SYSTEMATIC APPROACH TO WASTE PREVENTION

The Scottish Executive has made funding available to local authorities to minimise in-house waste from their services and powers granted under the Waste Minimisation Act 1998 allow them to take any steps necessary to minimise waste within their area.

Waste minimisation and prevention initiatives help local authorities meet their targets under the Landfill Allowance Scheme. The consultation asked a series of three questions on waste prevention; the first asked "Should the Scottish Executive take action to ensure local authorities do more on waste prevention? If so, what?"

Twenty-three out of the 55 respondents commenting on this question agreed that the Scottish Executive should take action, although, 13 respondents (including 10 local authorities) felt that more funding would be required. As one local authority noted, "However it is one thing to prepare a plan quite another to implement it. This Council has already asked the SE what funding would be put in place to activate the plan. To date there has been no response on funding".

Ten respondents felt that the Scottish Executive should not take action and comments from these respondents (who included 5 local authorities) included a belief that current actions and targets suffice or that this should not be an Executive function.

A variety of suggestions for support were made, with 6 respondents asking for provision of clear targets, 2 respondents wanted to see statutory requirements, and 8 asking for examples of best practice. Four respondents asked that training be provided. Six respondents wanted to see guidance on procurement and 4 local authorities felt that each area should have a waste prevention officer or specialist staff. The need for sound data on which to base policies was raised by 4 respondents.

Guidance on the application of waste prevention schemes was requested by 6 respondents.

Interaction between local authorities and contractors, whether charities, voluntary organisations, retailers, manufacturers or suppliers, was seen as an issue with 10 respondents commenting on the need for better communication or co-operation.

Bringing waste awareness to the forefront of the agenda was mentioned by 9 respondents who saw raising awareness as a key area.

Six respondents commented that there may be a need for incentives for businesses and consumers in order to encourage them to play their part, and 2 respondents specifically noted that there should be an emphasis placed on the construction industry as there is potential for large environmental gains to be made in this area.

Three respondents felt better use could be made off the landfill tax allowance scheme.

Attendees at the consultation event were unsure as to the meaning of "systematic approach" and felt a national awareness campaign would be merited.

Question 39 asked, "Should the Scottish Executive lay down targets on local authorities in relation to waste prevention? If so, what should these targets require and how would this be measured?

Nineteen respondents agreed that local authority targets should be set and this included 4 local authorities.

Nine respondents provisionally agreed to this but felt that feasibility studies may be needed first to identify how this could be measured and base data to measure against. Five respondents (including 4 local authorities) wanted to see targets set against absolute or reduction in waste tonnage or volume. Setting targets within the context of the National Waste Plan's aim to stop growth by 2010 was proposed by 5 respondents.

"It is unclear whether an adequate basis for establishing and monitoring any such targets yet exists therefore, it may be worth waiting until the improved data collection over the last few years has settled in terms of MSW arisings so that targets can be based on accurate underlying figures."
Other public body / publicly-funded body

Five respondents agreed with the need for targets but felt these should be set more widely; perhaps covering the whole public sector, while 4 respondents felt that there should be targets for individual local authority departments.

However, 12 out of the 53 respondents answering this question disagreed and this included 5 local authorities. These respondents felt that targets would prove impractical and have difficulties in measuring or quantifying waste prevention, or that differences in areas may mean some authorities would have advantages over others. Three respondents suggested measurements based on waste per head of population and 1 local authority felt these should be based on residual waste arisings.

Five local authorities and 2 other respondents felt that there were already a great many targets for local authorities and examples given included landfill, recycling, diversion and EU regulations amongst others, and that another was not needed.

Question 40 asked, "Do local authority officers require more training on the skills needed to encourage waste prevention? If so, what training is required and who should provide it?"

Twenty-two of the 47 respondents commenting here agreed with the need for training, although 7 disagreed or felt these skills do (or should) already exist. In addition to training, 7 respondents saw the need for some form of knowledge exchange or a forum for information sharing.

"Good quality, practical training which concentrates on learning from real life situations, and best practice schemes and guidance from across the UK would be helpful. It would also be valuable for local authority officers in this field to receive media and public relations training and this can be invaluable in assisting a scheme to become successful." Academic / Professional

Five respondents were unsure as to what training could be offered, either because they did not have enough information on which to base their opinion or because they felt this could depend on the skill level of individual staff.

The types of training identified included:

• Waste prevention (12 respondents);
• Practical training including examples and best practice (11 respondents);
• Media or marketing skills (4 respondents);
• The role of agencies involved in waste prevention (3 respondents);
• Training on composting programmes (3 respondents);
• Training on community based projects (including training for those in the community (3 respondents).

The training could be provided by:

• Training from local authority specialist staff including Waste Prevention Officers and waste management staff (5 respondents);
• Chartered Institute of Waste Management (2 respondents);
• WRAP (2 respondents).

In addition, 3 respondents saw the need for training for all council staff, not simply those in Waste Departments, and 2 respondents felt that all public sector organisations should receive this training.

Two respondents felt the training should be free and 5 others suggested that training should be funded by the Scottish Executive. Three respondents noted that this training already exists but may be underused due to cost considerations.

A co-ordinated approach across all local authorities was suggested by 4 respondents and 2 respondents wanted to see training co-ordinated with the construction and manufacturing industries.

10.8 FUNDING FOR LOCAL AUTHORITIES' WASTE PREVENTION WORK

The consultation mentions that in Ireland there is a specific fund for local authority waste prevention work and in Scotland some Strategic Waste Fund awards include provision for waste prevention. The consultation acknowledged the need for funding to provide measurable gains and value for money and asked " Do consultees have any comments on the allocation of Strategic Waste Fund resources to waste prevention work?"

Thirty-eight respondents commented on question 41, with 15 commenting on the need to allocate more money to waste prevention or to reducing waste arisings. Eight respondents felt money should be allocated to waste prevention training and education. Six respondents felt that funding for waste prevention should be separate from the Strategic Waste Fund, and 3 respondents commented that allocation of resources should have the same priorities as at present. One local authority commented "The SWF does not lend itself to funding waste prevention work, as it is difficult to measure and therefore evaluate whether it has delivered value for money or how much it has cost per tonne. If waste prevention work is to be carried out a separate fund should be made available, otherwise recycling (providing tonnage) will continue to be given priority over waste prevention."

Restrictions on funding were mentioned by 7 respondents who commented that funding should only be allocated subject to production of a waste prevention plan, and 4 respondents felt any scheme would need to demonstrate best value before funding was allocated.

Specific funding requirements mentioned included a need for more "on the ground" funding, with 7 respondents requesting increased funding for pilot schemes, local groups and small projects. Home composting was seen as meriting extra funding by 6 respondents, while 4 respondents felt money should be spent on raising awareness.

Other issues included:

• More funding for real nappy initiatives (4 respondents);
• More funding to all types of waste reduction options (2 respondents);
• More funding provision for WRAP (1 respondent);
• More funding for SWAG (1 respondent);
• Less funding for community groups (as it does not provide best value) (1 respondent);
• Equal allocation to all local authorities (1 respondent);
• More resources for the Strategic Waste Prevention Fund (1 respondent);
• The need to recognise the contribution of waste prevention activities towards diversion targets (1 respondent).

Concerns were raised at the consultation event about what will happen after Strategic Waste Fund allocations change in 2007-08.

In summary,

• A number of consultees agreed with the proposal for Scottish local authorities to adopt a similar approach to that adopted in the London Borough of Barnet, and some noted that some local authorities already operate similar schemes.
• When asked specifically about the size of bins provided by local authorities for residual waste, the greatest level of support was for advice on the size of residual bins and frequency of collections (the highest level of support coming from local authorities). However, there were some comments that services need to be tailored to specific areas or types of household.
• In terms of green waste collection specifically, there was support for further research and guidance on green waste composting to minimise the effect on waste arisings. Again, there were some calls for this to be tailored to individual areas. There were some concerns that kerbside collection serves to discourage composting.
• Although there was support for the Executive to consider amending the existing regulations allowing charges to be made for the collection of other types of household waste, there were some concerns over a possible increase in fly-tipping or other illegal disposal practices.
• Views on whether or not the Executive should consider issuing guidance on charging for special uplifts of bulky items and garden waste were split. If guidance is to be issued, the main point raised by consultees was the need for a fair, consistent, basic charging structure and guidance on this.
• From those commenting, there was majority support for direct variable charging. Similarly, there was majority support for the Executive to carry out further work on incentives, with some consultees noting the importance of "positive" measures to help bring about waste awareness. A pilot scheme was suggested by some consultees.
• A greater proportion of consultees agreed with the proposal for waste management contracts or service level agreements to include incentives for waste prevention than disagreed. A significant number also noted that there was scope for provisions on waste prevention in local authority contracts.
• A majority of consultees agreed that the Executive should take action to ensure local authorities do more on waste prevention, although funding for this was perceived by some to be an issue. It was also noted that other types of organisations also have a part to play in this. In terms of setting targets for local authorities in relation to waste prevention, a greater number of consultees agreed with this than disagreed, although there were some queries as to what targets should be set against. Some respondents also noted a need for training in this area.
• There were some comments on the need to allocate more money to waste prevention or to waste arisings, although there are concerns as to what the position will be in 2007-08 when Strategic Waste Fund resources are scheduled to change.

10.9 OTHER ISSUES

One final question was asked of respondents and asked "Are consultees aware of any other action which could be undertaken to prevent waste? If so, what?"

The majority of comments from the 50 respondents answering question 42 summarised or reiterated points already made in their answers to previous questions.

The main points that were highlighted included:

• Education and raising awareness (11 respondents);
• Following successful examples from overseas countries (4 respondents);
• The need to change habits and attitudes (3 respondents);
• The need for manufacturers and retailers to play a part in waste reduction (3 respondents);
• The need for an holistic approach rather than individual initiatives (3 respondents);
• The anomaly in LATS regarding home composting (2 respondents);
• Facilities for recycling plastic (2 respondents);
• The need for action across all sectors (2 respondents);
• More work on eco-footprints (2 respondents).

While the consultation was generally well received, four responses contained criticism that,

• A large amount of paper had been wasted by poor layout;
• It was a missed opportunity and lacks ambition;
• Many questions relate to "soft issues" which would have little effect;
• Education should have played a more prominent role.

Three respondents gave examples of other action and these are summarised below:

Innovative thinking (Individual)
"Consideration could be given to supporting innovative thinking at whatever level that is needed."

The use of new technologies (Community council)
"Research the latest technology for Energy from Waste with minimum pollution problems."

Closed loop recycling (Packaging)
"Closed loop recycling prevents waste ending up in landfill."

In addition, two substantial responses were submitted which did not address the consultation on a question by question basis but which detailed the respondents policies and priorities. One, from a political party, explained the party's policy on Zero Waste:

Zero Waste, or preventing waste at source, targets production and distribution to prevent the possibility of waste and can benefit both the environment and save money. The milk-bottle delivery system was given as "a prime example of a virtually waste-free (and zero-emissions) delivery/collection system." As well as environmental and economic benefits, the response deals with how businesses can aim for zero waste and gives examples of best practice, both from the UK and overseas. The response urges the Scottish Executive to take action towards this aim and concludes "If we accept that Zero Waste will deliver substantial social, economic and environmental benefits, what is to stop us from publicly declaring that Zero Waste is our intention?"

The other, from an Environment NGO, outlined their key priorities for waste prevention. At some points it was possible to refer these back to specific questions and so, where possible, their opinion has been included at the relevant chapter.

This response also highlighted the need to work towards "zero waste". Other main points raised included the need for mandatory targets across all sectors and at all points of the life-cycle. A need for tougher regulation which should be well designed and targeted. Funding should be targeted at the top of the waste hierarchy; "So far Scotland has addressed the middle of the hierarchy with action to facilitate recycling and there is now a danger that the next phase will be recovery, missing what should be the critical first area for action - prevention. There is an urgent need to re-evaluate strategy and retrace our steps, before we progress any further down the hierarchy. In short we have focused on a solution to 'waste disposal' and not 'waste creation'." The need for a culture change in how waste is perceived, processed and regulated. Problems with effective implementation of the Landfill Directive. They concluded "We want Scotland to take a lead in Waste Prevention in the UK and to push the rest of the UK in line as it has done in other areas most notably concessionary travel and controls on public smoking. "